Flagler College President, Lobbyist JOHN DELANEY, Rudely Refuses to Provide Video Deposition From Title IX Case (Updated)

UPDATE: President Delaney later wrote me on Facebook that he did not intend to be rude, but that Flagler College, Inc. did not order or have the printed deposition; I sent it to him, explaining it is already a public record on PACER. I gave him the court reporter's contact information, asking him to send me the videotape of the deposition of James Springfield, HR Director of Flagler College, Inc., who is now running for St. Augustine Cirty Commission.

I've been researching the federal court lawsuit in which Mr. James Springfield, candidate for City Commission, was accused of retaliating against Dr. Tina Jaeekle, a fifteen-year professor fired after she raised concerns about alleged sexual harassment of women students by JOEL BOLANTE, former UnderSheriff under Sheriff DAVID SHOAR, who legally changed his name from "HOAR" in 1994.

Mr. Springfield is running against Nelmar Terrace neighborhood community activist Ms. Melinda Rakoncay.

Mr. Springfield retired from Flagler College as HR Director, serving under Flagler College President JOSEPH JOYNER, former School Superintendent.  

Controversial Flagler College Chancellor WILLIAM LEE PROCTOR, Flagler College President JOSEPH JOYNER and other Flagler College administrators abruptly left in the wake of the case of Jaeckle v. Flagler College Inc..

I've been studying federal court filings, and noted that Mr. Springfield's deposition was videotaped. So I asked for a copy of the videotape, in order to gauge his credibility, given the many times he told Dr. Jaeckle's lawyers that he could not "recall" basic facts.  On paper, it reads like Robert Kennedy questioning James Riddle Hoffa, circa 1958.  The video would be enlightening.

The response from Flagler College and the plaintiff's lawyers were disrespectful and disdainful.  

• A putative paralegal working for the plaintiff's Ponte Vedra attorney refused to so much as take a message, shrilly stating "no comment" before hanging up the telephone,  Harrumph,
• Flagler College President JOHN DELANEY wrote me, "We're not in that business, Ed," explaining that "As a private institution, we do not as a rule provide documents as a public institution would have to under public records and Sunshine Laws. Be safe."   DELANEY did not return a telephone message left with his secretary,  Double Harrumph.

What nasty, noisome cognitive misers. 

How utterly unprofessional. 

Jesus wept.

How contrarily, contumaciously contemptuous of our American Right to Know about a City Commission candidate -- Flagler College's former Human Resources Director -- in a town where two current Flagler College professors currently occupy two of five City Commission seats.

Flagler College, Inc. was named after a Robber Baron, Henry Morrison Flagler.

FCI is still run like a Southern plantation.

FCI's maladministration is a matter of public record in federal court.

FCI's President before DELANEY was paid some $500,000/year.  (The most recent IRS Form 990 on Guidestar website was from 2020),

I'd heard that JOHN DELANEY was enlightened, but evidently, not so much!

FCI President DELANEY, in arrogantly refusing to provide the video deposition, acts like a Robber Baron, in the spirit of Commodore Cornelius Vanderbilit, who alleged said, "Let the public be damned."

Corporate lawyer JOHN DELANEY is the President of Flagler College, Inc.  DELANEY is also Of Counsel to the ROGERS TOWERS corporate law firm, former President of the University of North Florida, former Mayor of Jacksonville and a lobbyist with THOMAS MARTIN FIORENTINO's lobbying firm, THE FIORENTINO GROUP. 

DELANEY's lobbying reports show that his clients have included these 39 organizations:

1. St. Johns County, 
2. St. Johns County Sheriff, 
3. St. Johns County Clerk of Courts and Comptroller, 
4. PARC GROUP, 
5. EASTLAND PARTERS, LLC
6. PGA Tour, Inc., 
7. FLAGLER HOSPITAL, 
8. Flagler Health, 
9. Crowley Maritime, 
10. City of Atlantic Beach, 
11. Duval County Public Schools, 
12. Jacksonville Icemen Hockey, 
13. Jacksonville Port Authority, 
14. Jacksonville Aviation Authority, 
15. Jacksonville Transporation Authority, 
16. Mental Health Resource Center, Inc./Renaissance Behavioral Health Systems, Inc., 
17. North Florida School of Special Education, 
18. CareerSource Northeast Florida, Inc., 
19. Chance Partners,LLC, 
20. Clay County Circuit Court Clerk, 
21. Estuary LLC, 
22. Flagler County Clerk of Court and Comptroller, 
23. Florida Court Clerks and Comptrollers, 
24. HDR Engineering, Inc., 
25. Intuition Ale Works, 
26. KIPP Schools, 
27. Loop's Nursery and Greenhouses, Inc., 
28. Mitchell International, Inc., 
29. Monique Foundation for Children, Inc., 
30. Mylan Specialty, LP, 
31. Sustainable Water Investment Group, 
32. Tactical Air Support, Inc., 
33. Teach America, Inc., 
34. Uber Technologies, Inc. and Affiliates, 
35. UF Health Jacksonville, 
36. VidaCann LLC, 
37. Vulcan Materials, 
38. World Golf Hall of Fame and Museum, 
39. YMCA of Florida's First Coast.

Without disclosing any of these 39 connections on-air, DELANEY is frequently featured, feted and uncritically quoted as a well-connected local authority figure, on Jacksonville's NPR affiliate, WJCT, and its ironically-named "First Coast Connect" program, hosted by Ms. Melissa Ross daily at 9 AM.

Louche lobbyist JOHN DELANEY's snooty response to me suggests a contiuation of the arrogant maladministration of Flagler College.

Flagler College, Inc. and its ruling oligarchs want to stop us from ever watching Mr. James Springfield's videotape deposition as he runs for Commissioner as the local Establishment's preferred candidate for City Commission.

UPDATE: President Delaney later wrote me on Facebook that he did not intend to be rude, but that Flagler College, Inc. did not order or have the printed deposition; I sent it to him, explaining it is already a public record on PACER. I gave him the court reporter's contact information, asking him to send me the videotape of the deposition of HR Director James Springfield, who is running for City Commission.

Here are the e-mails establishing DELANEY's insouciant response to my respectful request for the James Springfield video deposition:

-----Original Message-----
From: Ed Slavin <easlavin@aol.com>
To: info@pcreporting.net <info@pcreporting.net>; ryan@trwlaw.com <ryan@trwlaw.com>; rsniffen@sniffenlaw.com <rsniffen@sniffenlaw.com>; mspellman@sniffenlaw.com <mspellman@sniffenlaw.com>; fdupchurch@ubulaw.com <fdupchurch@ubulaw.com>; jdelaney@flagler.edu <jdelaney@flagler.edu>
Cc: wdelaney@moderncities.com <wdelaney@moderncities.com>; dunbar@gannett.com <dunbar@gannett.com>; sheldon.gardner@staugustine.com <sheldon.gardner@staugustine.com>; sheltonhull@gmail.com <sheltonhull@gmail.com>; aschindler@firstcoastnews.com <aschindler@firstcoastnews.com>; jessicaclark@firstcoastnews.com <jessicaclark@firstcoastnews.com>; jpalombo@wjct.org <jpalombo@wjct.org>; mross@wjct.org <mross@wjct.org>; eaverysmith@rtlaw.com <eaverysmith@rtlaw.com>; tupchurch@citystaug.com <tupchurch@citystaug.com>; nsikeskline@citystaug.com <nsikeskline@citystaug.com>; rhorvath@citystaug.com <rhorvath@citystaug.com>; jvaldes@citystaug.com <jvaldes@citystaug.com>; bblonder@citystaug.com <bblonder@citystaug.com>; ralf@ralfbrookesattorney.com <ralf@ralfbrookesattorney.com>; jregan@citystaug.com <jregan@citystaug.com>; ilopez@citystaug.com <ilopez@citystaug.com>; shorsteinb@sao7.org <shorsteinb@sao7.org>; larizzar@sao7.org <larizzar@sao7.org>; sheriff@sjso.org <sheriff@sjso.org>; comdrumrell@cityofsab.org <comdrumrell@cityofsab.org>; comdsamora@cityofsab.org <comdsamora@cityofsab.org>; commengland@cityofsab.org <commengland@cityofsab.org>; combsweeny@cityofsab.org <combsweeny@cityofsab.org>; comugeorge@cityofsab.org <comugeorge@cityofsab.org>; mroyle@cityofsab.org <mroyle@cityofsab.org>; bcc5hdean@sjcfl.us <bcc5hdean@sjcfl.us>; bcc4jblocker@sjcfl.us <bcc4jblocker@sjcfl.us>; bcc1cwhitehurst@sjcfl.us <bcc1cwhitehurst@sjcfl.us>; bcc2sarnold@sjcfl.us <bcc2sarnold@sjcfl.us>; bcc3pwaldron@sjcfl.us <bcc3pwaldron@sjcfl.us>; dmigut@sjcfl.us <dmigut@sjcfl.us>; executiveinvestigationscomplaints@fdle.state.fl.us <executiveinvestigationscomplaints@fdle.state.fl.us>; corruption@usdoj.gov <corruption@usdoj.gov>; bpatty@stjohnsclerk.com <bpatty@stjohnsclerk.com>; mminer@stjohnsclerk.com <mminer@stjohnsclerk.com>; waltbog@nytimes.com <waltbog@nytimes.com>
Sent: Wed, Sep 28, 2022 2:54 pm
Subject: Preservation and disclosure of Mr. James Thomas Springfield's video deposition in Jaeckle v. Flagler College, Inc. (FCI)

Dear Messrs. Springfield, Delaney, Upchurch, Sniffen, Spellman and Williams, and Ms. Jackson-Williams:
1. Would you please be so kind as to preserve -- and would one of you kindly send me a copy today of -- the video deposition of Mr. James Springfield in the federal court case of Jaeckle v. Flagler College, Inc.?  

2. Mr. James Springfield is currently a candidate for St. Augustine City Commission.  

3. Mr. James Springfield is former Flagler College Humran Resources Director.

4. Mr. James Springfield's alleged discriminatory and retaliatory misconduct was at issue in federal court litigation involving alleged retaliation for protected activity concerning Title IX rights. 

5. Mr. Springfield later resigned.

6. With IRS-reported assets and endowment in hundreds of millions of dollars, Flagler College, Inc. is a putative "non-profit."  

7. Rose Kennedy's favorite Bible verse was, "to whom much is given, much is expected."

8. FCI is a frequent recipient of federal, state and local government benefits and largesse, including both direct expenditures and tax expenditures. 

9. FCI is required to comply with federal tax and civil rights laws. 

10. FCI, as a Florida state government contractor, is often required to comply with Open Records laws, and to include such clauses in its contracts.  F.S. 119.0701.  

11. FCI states that its  purposes are "to provide a supportive and challenging environment in which students acquire knowledge, exercise good citizenship, and adhere to high ethical standards."  https://www.guidestar.org/profile/59-1157081

12. Two (2) of our five (5) current St. Augustine City Commissioners are Flagler College, Inc. professors -- 40% of our current City Commissioners. 

13. Former Flagler College Human Resources Director James Springfield's federal court retaliation and discrimination deposition, his e-mail memos and his declaration are already public records in federal court. 

14. To be truly informed voters, all St. Augustine residents (especially including our friends and neighbors who are Flagler College, Inc. students, faculty, staff and alumni/ae) have a reasonable expectation of probity from our local institutions, including disclosures of potential conflicts of interest.   

15. Conflicts of interests are to be scrupulously guarded against. See, e.g., United States v. Mississippi Valley Generating Co., 364 U.S. 520, 548 (1961)("the 'Dixon-Yates' case," involving TVA rivals' conflicts of interest in a proposed Memphis coal-fired powerplant), citing Matthew 6:24 -- "no [person] can serve two masters," holding that laws and rules preventing conflicts of interest are aimed "not only at dishonor but at conduct that tempts dishonor."   All conflict of interest laws are based upon Matthew 6:24 ("A man cannot serve two masters"), which the unanimous Supreme Court decision by Chief Justice Earl Warren deemed to be both a "moral principle" and a "maxim which is especially pertinent if one of the masters happens to be economic self-interest."  

16. All Florida residents and all American citizens have a presumptive right to view Mr. Springfield's video deposition, the transcript of which is already evidence in federal court.  17. Is it a conflict of interest for Flagler College, Inc. to withhold the video deposition in hopes that it will somehow obstruct, discourage and prevent people from learning about FC's alleged discrimination and retaliation and potential influence over a City Commissioner seeking election here?  You tell me.

18. "Character counts," as St. Johns County Schools' curriculum teaches. 

19. Again, Mr. James Springfield's sworn printed deposition is already a public record.  (Enclosed, with sworn declaration). 

20. What does anyone have to hide, e.g.,  in so rudely stiffing my request?  

21. Please explain it to me, like I was a six year old.

22. James Madison wrote in 1823, "A popular Government, without popular information, or the means of acquiring it, is but a Prologue to a Farce or a Tragedy; or, perhaps both. Knowledge will forever govern ignorance: And a people who mean to be their own Governors, must arm themselves with the power which knowledge gives."

23. Thank you in advance for sending me a copy of Mr. James Springfield's video deposition today, without any further flummery from FCI.   Please stay warm and dry amidst the weather today.

Cheers!

With kindest regards, I am,

Sincerely yours,

Ed Slavin

Box 3084

St. Augustine, Florida 32085-3084

www.edslavin.com

www.cleanupcityofstaugustine.blogspot.com

904-377-4998

-----Original Message-----
From: Delaney, John <JDelaney@flagler.edu>
To: Ed Slavin <easlavin@aol.com>
Cc: rsniffen@sniffenlaw.com <rsniffen@sniffenlaw.com>; mspellman@sniffenlaw.com <mspellman@sniffenlaw.com>; fdupchurch@ubulaw.com <fdupchurch@ubulaw.com>; jspringfield@mac.com <jspringfield@mac.com>; sheldon.gardner@staugustine.com <sheldon.gardner@staugustine.com>; sheltonhull@gmail.com <sheltonhull@gmail.com>; aschindler@firstcoastnews.com <aschindler@firstcoastnews.com>; jessicaclark@firstcoastnews.com <jessicaclark@firstcoastnews.com>; jpalombo@wjct.org <jpalombo@wjct.org>; mross@wjct.org <mross@wjct.org>; waltbog@nytimes.com <waltbog@nytimes.com>
Sent: Wed, Sep 28, 2022 9:37 am
Subject: Re: James Springfield video deposition in Jaeckle v. Flagler College, Inc.

As a private institution, we do not as a rule provide documents as a public institution would have to under public records and Sunshine Laws. Be safe. 

Sent from my iPad

On Sep 28, 2022, at 9:28 AM, Ed Slavin <easlavin@aol.com> wrote:



Dear Mr. Delaney:
What do you mean by that?

With kindest regards, I am,

Sincerely yours,

Ed Slavin

www.edslavin.com

www.cleanupcityofstaugustine.blogspot.com

-----Original Message-----
From: Delaney, John <JDelaney@flagler.edu>
To: Ed Slavin <easlavin@aol.com>
Cc: rsniffen@sniffenlaw.com <rsniffen@sniffenlaw.com>; mspellman@sniffenlaw.com <mspellman@sniffenlaw.com>; fdupchurch@ubulaw.com <fdupchurch@ubulaw.com>; jspringfield@mac.com <jspringfield@mac.com>; sheldon.gardner@staugustine.com <sheldon.gardner@staugustine.com>; sheltonhull@gmail.com <sheltonhull@gmail.com>; aschindler@firstcoastnews.com <aschindler@firstcoastnews.com>; jessicaclark@firstcoastnews.com <jessicaclark@firstcoastnews.com>; jpalombo@wjct.org <jpalombo@wjct.org>; mross@wjct.org <mross@wjct.org>; waltbog@nytimes.com <waltbog@nytimes.com>
Sent: Wed, Sep 28, 2022 9:23 am
Subject: Re: James Springfield video deposition in Jaeckle v. Flagler College, Inc.

We aren’t in that business, Ed. 

Sent from my iPad

On Sep 28, 2022, at 9:13 AM, Ed Slavin <easlavin@aol.com> wrote:



Dear President Delaney and Messrs. Upchurch, Sniffen & Spellman:
1. Would one of you please be so kind as to send me the video deposition of Mr. James Springfield in Jaeckle v. Flagler College, Inc.?

2. I have the printed transcript from PACER.  (Enclosed).

3. Mr. Springfield is a candidate for St. Augustine City Commission.  He has agreed to an interview about his work at Flagler College.  

4. As Jefferson said, "a public office is a public trust."

Thank you.

With kindest regards, I am,

Sincerely yours,

Ed Slavin

Box 3084

St. Augustine, Florida 32085-3084

www.edslavin.com

www.cleanupcityofstaugustine.blogspot.com

-----Original Message-----
From: Jim Springfield <jspringfield@mac.com>
To: Ed Slavin <easlavin@aol.com>
Sent: Wed, Sep 28, 2022 4:40 am
Subject: Re: James Springfield work as Flagler College, Inc. HR Director

Ed,

I will be happy to discuss these questions with you but I am getting my house ready for the storm. We are in a flood zone and we get hit pretty hard usually. 

Maybe we can talk tomorrow?

Jim

"I love it when a plan comes together. " Hannibal of the A-Team

On Sep 27, 2022, at 8:55 PM, Ed Slavin <easlavin@aol.com> wrote:



Dear Mr. Springfield:

1. Would you please be so kind as to call me tomorrow to discuss your handling of Title IX complaints at Flagler College, Inc.?  

2. What qualified you to be a Title IX investigator?

3. How would you characterize your work?

4. What qualifies you to be a City Commissioner?

5. Why did you resign?

6. Please send me any pertinent documents.

https://cleanupcityofstaugustine.blogspot.com/2020/05/jaeckle-v-flagler-college-inc-second.html

https://cleanupcityofstaugustine.blogspot.com/2020/05/chancellor-william-lee-proctor-retires.html

https://cleanupcityofstaugustine.blogspot.com/2019/11/flagler-college-inc-removes-faculty.html

https://cleanupcityofstaugustine.blogspot.com/2019/11/whistleblower-retaliation-joel-bolante.html

Thank you. 

With kindest regards, I am,

Sincerely yours,

Ed Slavin

Box 3084

St. Augustine, Florida 32085-3084

www.edslavin.com

www.cleanupcityofstaugustine.blogspot.com

www.staugustgreen.com

904-377-4998

U.S. District Court
Middle District of Florida (Jacksonville)
CIVIL DOCKET FOR CASE #: 3:19-cv-01323-TJC-MCR

Jaeckle v. Flagler College, Inc. Assigned to: Judge Timothy J. Corrigan Referred to: Magistrate Judge Monte C. Richardson Case in other court:  In the Circuit Court, Seventh Judicial Circuit, 55-18-CA-886-A0-00XX Cause: 28:1441 Notice of Removal-Breach of Contract

Date Filed: 11/13/2019 Date Terminated: 03/05/2021 Jury Demand: Both Nature of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question

Plaintiff
Tina Jaeckle	represented by	Keely T. Lockwood   Keely Lockwood, PLLC   3845 W. Eau Gallie Blvd., Suite 104   Melbourne, FL 32934   404-784-3885   Email: keely@shanesmithlegal.com  LEAD ATTORNEY  ATTORNEY TO BE NOTICED Ryan Williams   Coastal Law Group   105 Solana Road, Suite C   Ponte Vedra Beach, FL 32082   904/930-4100   Fax: 904/422-0999   Email: service@trw.law  LEAD ATTORNEY  ATTORNEY TO BE NOTICED Shane M. Smith   Shane M. Smith, P.A.   Suite 104   3845 W. Eau Gallie Blvd.   Melbourne, FL 32934   321/724-1919   Email: service@shanesmithlegal.com  LEAD ATTORNEY  ATTORNEY TO BE NOTICED
V.
Defendant
Flagler College, Inc.	represented by	Robert Jacob Sniffen   Sniffen & Spellman, PA   123 N Monroe St.   Tallahassee, FL 32301-1509   850/205-1996   Fax: 850/205-3004   Email: rsniffen@sniffenlaw.com  LEAD ATTORNEY  ATTORNEY TO BE NOTICED Lisa Barclay Fountain   Sniffen & Spellman, PA   123 N Monroe St.   Tallahassee, FL 32301-1509   850/205-1996   Fax: 850/205-3004   Email: lfountain@sniffenlaw.com  ATTORNEY TO BE NOTICED Michael P. Spellman   Sniffen & Spellman, PA   123 N Monroe St.   Tallahassee, FL 32301-1509   850/205-1996   Fax: 850/205-3004   Email: mspellman@sniffenlaw.com  ATTORNEY TO BE NOTICED

Date Filed	#	Docket Text
11/13/2019	1	COMPLAINT and NOTICE OF REMOVAL from In the Circuit Court of the Seventh Judicial Circuit in and for St. Johns County, Florida, case number 55-2018-CA-000886-A0-00XX filed in State Court on July 17, 2018. Filing fee $ 400, receipt number 113A-16139756 filed by FLAGLER COLLEGE. (Attachments: # 1 State Court COMPLAINT Exhibit 1 - Amended Complaint, # 2 State Court Pending Motions Exhibit 2 - Plaintiff Motion for Default, # 3 State  Court Docket Sheet Exhibit 3 - Docket Sheet, # 4 State Court Other Documents Exhibit 4 - Other State Court Documents, # 5 Civil Cover Sheet Exhibit 5 - Civil Cover Sheet)(Spellman, Michael) (Entered: 11/13/2019)
11/13/2019	2	NOTICE of Filing Civil Cover Sheet by FLAGLER COLLEGE re 1 Notice of Removal (Spellman, Michael) Modified to edit text on 11/14/2019 (KKH). (Entered: 11/13/2019)
11/13/2019	3	NEW CASE ASSIGNED to Judge Timothy J. Corrigan and Magistrate Judge Monte C. Richardson. New case number: 3:19-cv-1323-J-32MCR. (SJB) (Entered: 11/13/2019)
11/13/2019	4	NOTICE of Appearance by Ryan Williams on behalf of TINA JAECKLE (Williams, Ryan) (Entered: 11/13/2019)
11/13/2019	5	NOTICE of Appearance by Robert Jacob Sniffen on behalf of FLAGLER COLLEGE (Sniffen, Robert) (Entered: 11/13/2019)
11/13/2019	6	NOTICE of Appearance by Lisa Barclay Fountain on behalf of FLAGLER COLLEGE (Fountain, Lisa) (Entered: 11/13/2019)
11/14/2019	7	COMPLAINT against Flagler College, Inc. with Jury Demand, originally filed on 7/17/2018 in the Seventh Judicial Circuit, St. John's County, case #2018-CA-886 filed by Tina Jaeckle. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4Exhibit D)(KKH) (Entered: 11/14/2019)
11/14/2019	8	MOTION for Judicial Default, originally filed on 11/13/19 in the Seventh Judicial Circuit, St. John's County by Tina Jaeckle. (KKH) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 11/14/2019)
11/18/2019	9	ORDER denying without prejudice 8 Motion for default. Signed by Magistrate Judge Monte C. Richardson on 11/18/2019. (ADM) (Entered: 11/18/2019)
11/19/2019	10	NOTICE of designation under Local Rule 3.05 - track 2. Signed by Deputy Clerk on 11/19/2019. (Attachments: # 1Case Management Report form, # 2 Consent to US Magistrate Judge Jurisdiction letter and form)(MD) (Entered: 11/19/2019)
11/20/2019	11	ANSWER and affirmative defenses to 7 Complaint with Jury Demand by Flagler College, Inc..(Spellman, Michael)(Entered: 11/20/2019)
11/20/2019	12	CERTIFICATE of interested persons and corporate disclosure statement re 10 Related case order and track 2 notice by Flagler College, Inc.. (Spellman, Michael) (Entered: 11/20/2019)
11/25/2019	13	CERTIFICATE of interested persons and corporate disclosure statement re 10 Related case order and track 2 notice by Tina Jaeckle. (Williams, Ryan) (Entered: 11/25/2019)
12/21/2019	14	CASE MANAGEMENT REPORT. (Spellman, Michael) (Entered: 12/21/2019)
01/09/2020	15	NOTICE of unavailability of counsel by Tina Jaeckle from March 13, 2020 to March 20, 2020. (Williams, Ryan) (Entered: 01/09/2020)
01/09/2020	16	NOTICE of unavailability of counsel by Tina Jaeckle from May 26, 2020 to May 29, 2020. (Williams, Ryan) (Entered: 01/09/2020)
01/09/2020	17	NOTICE of unavailability of counsel by Tina Jaeckle from November 23, 2020 to November 25, 2020. (Williams, Ryan) (Entered: 01/09/2020)
01/09/2020	18	NOTICE of unavailability of counsel by Tina Jaeckle from December 28, 2020 to December 31, 2020. (Williams, Ryan) (Entered: 01/09/2020)
01/14/2020	19	CASE MANAGEMENT AND SCHEDULING ORDER: Discovery deadline is 1/11/2021; Dispositive and Daubert motions due by 2/5/2021; Conduct mediation hearing by 2/18/2021; Pretrial statement due by 6/17/2021; Final Pretrial Conference set for 6/23/2021 at 10:00 AM in Courtroom 10 D before Judge Timothy J. Corrigan; and, Jury Trial set for trial term commencing 7/6/2021 at 9:00 AM in Courtroom 10 D before Judge Timothy J. Corrigan. Signed by Deputy Clerk on 1/14/2020. (Attachments: # 1 Mediation Report form, # 2 docket sheet)(MD) (Entered: 01/14/2020)
01/15/2020	20	Joint MOTION for clarification by Flagler College, Inc.. (Spellman, Michael) (Entered: 01/15/2020)
01/16/2020	21	ORDER granting 20 Motion for clarification, resetting the case for an eight-day trial. The remainder of the deadlines set in the 19 CMSO remain. Signed by Judge Timothy J. Corrigan on 1/16/2020. (SEJ) (Entered: 01/16/2020)
01/21/2020	22	NOTICE of mediation conference/hearing to be held on February 18, 2021 at 10:00 AM before Richard ("Rick") Joyce. (Williams, Ryan) (Entered: 01/21/2020)
01/22/2020	23	CASE REFERRED to Mediation. (KKH) (Entered: 01/22/2020)
02/28/2020	24	NOTICE of Appearance by Shane M. Smith on behalf of Tina Jaeckle (Smith, Shane) (Entered: 02/28/2020)
02/28/2020	25	MOTION to Amend Complaint and Demand for Jury Trial by Tina Jaeckle. (Attachments: # 1 Exhibit Second Amended Complaint and Demand for Jury Trial)(Williams, Ryan) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 02/28/2020)
03/13/2020	26	MEMORANDUM in opposition re 25 Motion to Amend / Correct / Modify / Supplement filed by Flagler College, Inc.. (Spellman, Michael) (Entered: 03/13/2020)
03/16/2020	27	MOTION for Miscellaneous Relief, specifically Leave to Reply to Defendant's 26 Memorandum of Law in Opposition to Plaintiff's Motion to Amend Complaint by All Plaintiffs. (Williams, Ryan) Modified to create docket relationship on 3/17/2020 (KKH). (Entered: 03/16/2020)
03/16/2020	28	MEMORANDUM in opposition re 27 Motion for Miscellaneous Relief filed by Flagler College, Inc.. (Attachments: # 1Exhibit GG v. Grindle, # 2 Exhibit Order on Motion to Dismiss, # 3 Exhibit Order on Motion for Summary Judgment, # 4Exhibit Order Affirming Order on Summary Judgment, # 5 Exhibit Jury Instructions and Verdict Form)(Spellman, Michael) (Entered: 03/16/2020)
03/20/2020	29	ORDER denying 25 Motion to Amend; denying 27 Motion for Reply. Signed by Magistrate Judge Monte C. Richardson on 3/20/2020. (ADM) (Entered: 03/20/2020)
04/03/2020	30	OBJECTION to United States Magistrate Judge's Order 29 Entered March 20, 2020 Attachments: # 1 Exhibit A - Emails OC Refusal to Confer)(Williams, Ryan) Modified to edit text on 4/6/2020 (KKH). (Entered: 04/03/2020)
04/17/2020	31	RESPONSE re 30 Objection filed by Flagler College, Inc.. (Attachments: # 1 Exhibit, # 2 Exhibit)(Spellman, Michael) (Entered: 04/17/2020)
04/24/2020	32	ORDER directing Plaintiff to file a motion for leave to amend the complaint by 5/8/2020 and directing Defendant to respond by 5/22/2020. See Order for details. Signed by Judge Timothy J. Corrigan on 4/24/2020. (TNM) (Entered: 04/24/2020)
05/08/2020	33	MOTION for Leave to File Second Amended Complaint by Tina Jaeckle (Attachments: # 1 Exhibit Second Amended Complaint and Demand for Jury Trial)(Williams, Ryan). Motions referred to Magistrate Judge Monte C. Richardson. Modified on 5/8/2020 to edit text (JSG). (Entered: 05/08/2020)
05/08/2020	34	AMENDED DESIGNATION of E-Mail Address by Ryan Williams (Williams, Ryan). Modified on 5/8/2020 to edit text (JSG). (Entered: 05/08/2020)
05/22/2020	35	MEMORANDUM in opposition re 33 Motion to Amend / Correct / Modify / Supplement filed by Flagler College, Inc.. (Spellman, Michael) (Entered: 05/22/2020)
06/22/2020	36	ORDER granting 33 Plaintiff Tina Jaeckle's Motion for Leave to File Second Amended Complaint. The Clerk should file [33-1] the Second Amended Complaint and Demand for Jury Trial. Defendant Flagler College, Inc. should file its answer to the Second Amended Complaint no later than 7/7/2020. See Order for details. Signed by Judge Timothy J. Corrigan on 6/22/2020. (TNM) (KKH). (Entered: 06/22/2020)
06/23/2020	37	Second AMENDED COMPLAINT against Flagler College, Inc. with Jury Demand. filed by Tina Jaeckle. (Attachments: # 1Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(KKH) (Entered: 06/23/2020)
07/07/2020	38	MOTION to Strike or Alternatively, to Dismiss Plaintiff's Claim for Punitive Damages by Flagler College, Inc.. (Spellman, Michael) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 07/07/2020)
07/10/2020	39	Joint MOTION to Extend Certain Deadlines by Flagler College, Inc.. (Spellman, Michael) Modified to edit event type and text on 7/13/2020 (KKH). (Entered: 07/10/2020)
07/14/2020	40	ENDORSED ORDER granting 39 the parties' Joint Motion to Extend Certain Deadlines. The deadline for Plaintiff Tina Jaeckle's disclosure of expert reports is extended to 10/1/2020 and the deadline for Defendant Flagler College, Inc.'s disclosure of expert reports is extended to 11/1/2020. All other deadlines in 19 the Case Management and Scheduling Order remain in effect. Signed by Judge Timothy J. Corrigan on 7/14/2020. (TNM) (Entered: 07/14/2020)
07/15/2020	41	MOTION for Protective Order by Flagler College, Inc.. (Attachments: # 1 Exhibit Ex. 1 - Pl. Notice of Taking Deposition, # 2 Exhibit Ex. 2 - Pl. Amended Notice of Taking Deposition Duces Tecum, # 3 Exhibit Ex. 3 - Pl. Second Amended Notice of Taking Deposition Duces Tecum, # 4 Exhibit Ex. 4 - June 15, 2020 Letter, # 5 Exhibit Ex. 5 - June 18, 2020 Letter, # 6Exhibit Ex. 6 - June 28, 2020 Letter, # 7 Exhibit Ex. 7 - E-mail Correspondence, # 8 Exhibit Ex. 8 - E-mail Correspondence, # 9 Exhibit Ex. 9 - E-mail Correspondence)(Spellman, Michael) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 07/15/2020)
07/15/2020	42	Amended MOTION for Protective Order by Flagler College, Inc.. (Attachments: # 1 Exhibit Ex. 1 - Pl. Notice of Taking Deposition, # 2 Exhibit Ex. 2 - Pl. Amended Notice of Taking Deposition Duces Tecum, # 3 Exhibit Ex. 3 - Pl. Second Amended Notice of Taking Deposition Duces Tecum, # 4 Exhibit Ex. 4 - June 15, 2020 Letter, # 5 Exhibit Ex. 5 - June 18, 2020 Letter, # 6 Exhibit Ex. 6 - June 28, 2020 Letter, # 7 Exhibit Ex. 7 - E-mail Correspondence, # 8 Exhibit Ex. 8 - E-mail Correspondence, # 9 Exhibit Ex. 9 - E-mail Correspondence)(Spellman, Michael) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 07/15/2020)
07/20/2020	43	Second MOTION for Protective Order and Request for Expedited Review by Flagler College, Inc.. (Attachments: # 1Exhibit Ex. 1- Letter to Opposing Counsel)(Spellman, Michael) Motions referred to Magistrate Judge Monte C. Richardson. Modified to edit text on 7/21/2020 (KKH). (Entered: 07/20/2020)
07/21/2020	44	ORDER taking under advisement 42 Amended Motion for Protective Order; granting to the extent stated 43 Second Motion for Protective Order. Plaintiff's response to 42 Amended Motion is due July 29, 2020. Signed by Magistrate Judge Monte C. Richardson on 7/21/2020. (ADM) (Entered: 07/21/2020)
07/21/2020	45	RESPONSE in Opposition re 38 MOTION to Strike or Alternatively, to Dismiss Plaintiff's Claim for Punitive Damages filed by Tina Jaeckle. (Williams, Ryan) (Entered: 07/21/2020)
07/22/2020	46	Amended RESPONSE in Opposition re 38 MOTION to Strike or Alternatively, to Dismiss Plaintiff's Claim for Punitive Damages filed by Tina Jaeckle. (Williams, Ryan) Modified to edit text on 7/22/2020 (KKH). (Entered: 07/22/2020)
07/24/2020	47	RESPONSE in Opposition re 42 Amended MOTION for Protective Order filed by Tina Jaeckle. (Attachments: # 1 Exhibit 1 - Not of Dep Corp Rep, # 2 Exhibit 2 - Amnd Not of Dep Corp Rep, # 3 Exhibit 3 - OC - Counsel re Depos, # 4 Exhibit 4 - RW - OC re Depos, # 5 Exhibit 5 - OC - RW re Depos, # 6 Exhibit 6 - RW - OC re Depos, # 7 Exhibit 7 - Flagler Reopening, # 8 Exhibit 8 - Flagler Policy, # 9 Exhibit 9 - Flagler - Client - Outside Emp, # 10 Exhibit 10 - Springfield EM to Client)(Williams, Ryan) (Entered: 07/24/2020)
07/30/2020	48	NOTICE of Filing Additional Authority by Flagler College, Inc. re 42 Amended MOTION for Protective Order (Attachments: # 1 Exhibit Ex. 1)(Spellman, Michael) Modified to edit text on 7/31/2020 (KKH). (Entered: 07/30/2020)
07/31/2020	49	MOTION for Extension of Time to Complete Discovery and to Extend All Deadlines by Tina Jaeckle. (Attachments: # 1Exhibit 1 - Not of Dep Corp Rep, # 2 Exhibit 2 - Amnd Not of Dep Corp Rep, # 3 Exhibit 3 - OC - Counsel re Depos, # 4Exhibit 4 - RW - OC re Depos, # 5 Exhibit 5 - OC - RW re Depos, # 6 Exhibit 6 - RW - OC re Depos, # 7 Exhibit 7 - Flagler Not Available until October)(Williams, Ryan) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 07/31/2020)
08/05/2020	50	SUPPLEMENT re 49 MOTION for Extension of Time to Complete Discovery and to Extend All Deadlines by Tina Jaeckle. (Williams, Ryan) (Entered: 08/05/2020)
08/06/2020	51	NOTICE OF TELEPHONE HEARING: Telephone conference regarding all pending motions, including 38, 42, and 49, set for 8/20/2020 at 02:00 PM before Judge Timothy J. Corrigan. See Notice for details. (TNM) (Entered: 08/06/2020)
08/20/2020	52	MINUTE ENTRY. Proceedings held before Judge Timothy J. Corrigan: Telephone hearing on all pending motions held on 8/20/2020. Court Reporter: Shannon Bishop. (MD) (Entered: 08/21/2020)
08/25/2020	53	ORDER granting 38 Defendant's Motion to Strike or Alternatively, to Dismiss Plaintiff's Claim for Punitive Damages; granting in part 42 Defendant's Motion for Protective Order; granting in part 49 and 50 Plaintiff's Motion to Extend All Deadlines. Defendant should file an answer to 37 Plaintiff's Second Amended Complaint no later than 9/17/2020. See Order for details. Signed by Judge Timothy J. Corrigan on 8/25/2020. (TNM) (Entered: 08/25/2020)
08/26/2020	54	AMENDED CASE MANAGEMENT AND SCHEDULING ORDER: Fact discovery deadline is 1/11/2021; Conduct mediation hearing by 2/18/2021; Dispositive and Daubert motions due by 4/5/2021; Pretrial statement due by 8/19/2021; Final Pretrial Conference set for 8/25/2021 at 10:00 AM in Courtroom 10 D before Judge Timothy J. Corrigan; and, Jury Trial set for trial term commencing 9/7/2021 at 9:00 AM in Courtroom 10 D before Judge Timothy J. Corrigan. Signed by Deputy Clerk on 8/26/2020. (MD) (Entered: 08/26/2020)
08/26/2020	55	Unopposed MOTION for Miscellaneous Relief, specifically for Clarification re: ECF 53 by Flagler College, Inc.. (Spellman, Michael) (Entered: 08/26/2020)
08/28/2020	56	ORDER granting 55 Defendant's Unopposed Motion for Clarification. Paragraphs 56-63 and 65-81 of 37 the Second Amended Complaint are stricken. Defendant need not respond to those allegations in its answer, which should still be filed no later than 9/17/2020. Signed by Judge Timothy J. Corrigan on 8/28/2020. (TNM) (Entered: 08/28/2020)
09/17/2020	57	Defendant's ANSWER and affirmative defenses with Jury Demand to 37 Amended Complaint by Flagler College, Inc..(Spellman, Michael) (Entered: 09/17/2020)
02/17/2021	58	NOTICE of Filing Documents in Support of 59 Motion for Summary Judgment by Flagler College, Inc. (Attachments: # 1Exhibit Deposition transcript of Tina Jaeckle dated October 21, 2020, # 2 Exhibit Letter dated March 2, 2006, re Plaintiff's appointment, # 3 Exhibit Deposition transcript of Dr. Joseph Joyner dated October 26, 2020, # 4 Exhibit Deposition of Alan Woolfolk, as Corporate Representative, dated October 27, 2020, # 5 Exhibit Declaration of Alan Woolfolk (with exhibits), # 6 Exhibit Declaration of James T. Springfield (with exhibits), # 7 Exhibit Email from Plaintiff to Jim Springfield dated April 2, 2018, # 8 Exhibit Plaintiff's Answers to Defendant's First Interrogatories, # 9 Exhibit Deposition transcript of Dr. Emily Splane dated November 12, 2020, # 10 Exhibit Email from Emily Splane to Alan Woolfolk dated October 18, 2017, # 11Exhibit Email from Alan Woolfolk to Emily Splane dated November 27, 2017, # 12 Exhibit Annual Evaluation for Plaintiff dated February 1, 2018, # 13 Exhibit Email dated December 27, 2017, from Alan Woolfolk to Plaintiff, # 14 Exhibit Deposition transcript of James T. Springfield dated October 15, 2020, # 15 Exhibit Email dated March 15, 2018, from Jim Springfield to Plaintiff, # 16 Exhibit Student Reports regarding Plaintiff dated April 25, 2018, # 17 Exhibit Declaration of Dr. James Joyner, # 18 Exhibit Email chain between Plaintiff and Jim Springfield dated April 10, 2018, # 19 Exhibit Termination letter dated June 9, 2018, # 20 Exhibit Notes by Jim Springfield dated June 7, 2018, # 21 Exhibit Deposition transcript of Jennifer Melvin dated December 10, 2020, # 22 Exhibit Declaration of Jessica Kobryn (with exhibits), # 23Exhibit Deposition transcript of Jessica Kobryn, as Corporate Representative, dated October 14, 2020, # 24 Exhibit Email from Jessica Kobryn to Plaintiff dated May 30, 2018, # 25 Exhibit Memorandum from Jim Springfield to Dr. Joseph Joyner dated February 26, 2018, # 26 Exhibit Notes of Jim Springfield related to Bolante investigation, # 27 Exhibit Deposition transcript of Alan Woolfolk dated October 27, 2020)(Spellman, Michael) Modified to edit text and create docket entry relationship on 2/18/2021 (KKH). (Entered: 02/17/2021)
02/17/2021	59	MOTION for Summary Judgment by Flagler College, Inc.. (Spellman, Michael) (Entered: 02/17/2021)
02/17/2021	60	REQUEST for oral argument re 59 MOTION for Summary Judgment by Flagler College, Inc.. (Spellman, Michael) (Entered: 02/17/2021)
02/18/2021	61	Joint MOTION to Modify Certain Deadlines by Flagler College, Inc.. (Spellman, Michael) Modified to edit text on 2/19/2021 (KKH). (Entered: 02/18/2021)
02/22/2021	62	ORDER granting 61 Joint Motion to Modify Certain Deadlines. Mediation is continued to 3/1/2021. The parties shall select a new mediator and advise the Court of their selection no later than 2/24/2021. Plaintiff shall respond to 59Defendant's Motion for Summary Judgment no later than 3/22/2021. Defendant may reply no later than 4/5/2021.Signed by Judge Timothy J. Corrigan on 2/22/2021. (AGB) (Entered: 02/22/2021)
02/22/2021	63	NOTICE of mediation conference/hearing to be held on March 1, 2021 9:00 AM before Jason O'Steen. (Fountain, Lisa) (Entered: 02/22/2021)
02/26/2021	64	ORDER referring case to mediation and appointing Jason O'Steen as mediator in this action. Mediation to occur on 3/1/2021. Signed by Judge Timothy J. Corrigan on 2/26/2021. (Attachments: # 1 Mediation Report form, # 2 docket sheet)(MD) (Entered: 02/26/2021)
03/03/2021	65	MEDIATION report Hearing held on 03/01/2021. Hearing outcome: Settled.. (Williams, Ryan) (Entered: 03/03/2021)
03/04/2021	66	ORDER re 65 Mediation Report, directing the parties to file a joint motion for dismissal or other appropriate documents to close out the file by 5/3/2021. The Clerk should terminate all pending motions and close the file. Signed by Judge Timothy J. Corrigan on 3/4/2021. (TNM) (Entered: 03/04/2021)
03/29/2021	67	Joint STIPULATION of Dismissal Pursuant to Court Order 66 by Tina Jaeckle. (Williams, Ryan) Modified to edit text and create docket entry relationship on 3/29/2021 (KKH). (Entered: 03/29/2021)
03/29/2021	68	Amended Joint STIPULATION of Dismissal Pursuant to Court Order 66 by Tina Jaeckle. (Williams, Ryan) Modified to edit text and create docket entry relationship on 3/29/2021 (KKH). (Entered: 03/29/2021)
03/31/2021	69	ORDER re 68 the parties' Joint Stipulation of Dismissal Pursuant to Court Order, informing the parties that they must file a copy of the settlement agreement if they wish for the Court to retain jurisdiction to enforce its terms. The parties are directed either to file the settlement agreement or to re-file the stipulation without a provision about retaining jurisdiction no later than 4/12/2021. See Order for details. Signed by Judge Timothy J. Corrigan on 3/31/2021. (TNM) (Entered: 03/31/2021)
04/06/2021	70	Amended STIPULATION of Dismissal Pursuant to Court Order by Tina Jaeckle. (Williams, Ryan) Modified to edit text on 4/7/2021 (KKH). (Entered: 04/06/2021)
04/09/2021	71	ORDER dismissing this case with prejudice pursuant to 70 the parties' Amended Joint Stipulation of Dismissal Pursuant to Court Order. The Clerk should terminate all pending motions and close the file. Signed by Judge Timothy J. Corrigan on 4/9/2021. (TNM) (Entered: 04/09/2021)

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